Conflict of Interest

Introduction

Leodis Wealth Limited (“LW”) is required to establish and communicate to clients its Conflicts of Interest Policy.

The purpose of such policy is to identify, avoid, and (where avoidance is not possible) mitigate and manage the conflicts of interest that may arise when LW and its Representatives provide investment services and advice to clients.

The Conflicts of Interest Policy must contain mechanisms for the identification of conflicts of interest and measures and procedures for the avoidance, disclosure and mitigation of such conflicts.

What is a Conflict of Interest?

A conflict of interest is a situation in which someone in a position of trust has competing professional or personal interests. Such competing interests can make it difficult to fulfil his or her duties impartially. A conflict of interest may exist even if no unethical or improper act results from it.

The firm provide a range of services to a number of different clients. As a result circumstances may arise whereby the interest of the client may conflict with the interests of the firm or with those of another client. It is of vital importance that any risk of a conflict of interest is identified and managed appropriately, both to comply with FCA Rules and our wider duties to customers, and also to ensure that the integrity of our services is not eroded.

We are committed to identifying, monitoring and managing all actual and potential conflicts of interest that can arise between us and our clients and between clients of all areas of our Firm as a whole.

In dealing with and for our customers the firm observe two fundamental principles:

• that we do not disclose any information which has been given to us by our customers on a confidential basis, and do not use such information for our own benefit or for the benefit of any other customer, without the original customer’s consent; and

• that we act at all times in a way which ensures the fair treatment of all our customers. This means that we need to identify and deal with the potential for any conflicts of interest which may arise either between a customer and the interests of the Company or between two or more customers.

Below you will find a summary of the principal conflicts that exist in our business and the steps we take to mitigate them. If you have any questions on this policy in the first instance please raise them with your usual contact for your account.

Employee Dealing

It is usual for employees of financial institutions such as ours to undertake deals on their own behalf. We recognise that this can create a conflict with the duties owed to our clients. Therefore all of our employees and connected parties are required to comply with our Personal Account Dealing Policy which amongst other matters prohibits:

• dealing ahead of client orders; and dealing in an investment where they know, or should know, that a written recommendation, or a piece of research or analysis, in respect of that investment or any related investment is due to be published.

Gifts

On occasion our employees may give gifts or receive them from clients, companies or other institutions in recognition of services provided. We take care through our Gifts Policy to ensure that these gifts are not excessive and do not create an obligation or debt.

Inducements

We have relationships with many third parties such as product providers who may remunerate us via commission. Therefore we have processes in place to ensure that any fees or non monetary benefits provided by third parties do not impair our duty to act in the best interests of you, our client.

To eliminate influence from our research our analysts are prohibited from accepting inducements in return for favourable research.

Remuneration

The remuneration of Investment Managers within the Leodis Wealth usually consists of a salary, and from time to time a performance related bonus. We do not employ anybody who are remunerated on a commission only basis. Through these schemes we strive to ensure our employees remain motivated whilst at the same time ensuring the remuneration schemes do not
encourage inappropriate behaviour or excessive trading. We recognise this conflict and through our monitoring mechanisms remain alert to any potential abuse.

Dealing for your Account

We would like to draw to your attention that when we make a recommendation to you or deal for you we:

May match your order with that of another client. We will be acting on their behalf as well as yours and we may receive a commission or other charge from both parties.

Business Interests and Suitability

Where we use our discretion to make investment decisions or provide any advice or recommendations, we are required to ensure that our actions are suitable for our clients.

However, we or some other person connected with us, may have an interest, relationship or arrangement that is material to the service, transaction or investment concerned. This may include matters such as:

In addition, our employees may have an interest, relationship or arrangement whereby they act as a trustee, hold a power of attorney on behalf of a client. We require our employees to declare any such interests to us.

To manage such conflicts, we require our employees to comply with an independence policy obliging them to disregard the interest, relationship or arrangement concerned when acting on your behalf.

Aggregation and Allocation

We may combine (‘aggregate’) a transaction for you with our own orders and orders of other clients. The effect of aggregation may on some occasions work to your disadvantage.

Research

Leodis Wealth do not rely on any one source of research, therefore are not beholden to any one organisation. We ensure that the research used originates from a wide range of sources. Analysts may hold stock in the companies they research as a result of the decisions of the research process.

Leodis Wealth’s policy is to avoid any conflicts of interest between itself and staff on one hand and its clients on the other. In the event of such a conflict arising, it will always put the interests of the client first.

If there is a conflict between two or more clients, the company will act in the most fair and equitable way it can. For example, client orders for the same security will be dealt with in the order they are received, except in exceptional circumstances, such as when an aggregated order may be in the best interest of clients.